State v. Morales, 482 P.3d 819

Defendant pleaded guilty to first-degree criminal trespass and unlawful possession of methamphetamine and was found guilty of first-degree criminal mischief after a stipulated-facts trial.
He kicked open the victims’ back door, damaging the door and frame; victims paid $1,045 to repair the damage.
First-degree criminal mischief (ORS 164.365(1)(a)(A)) requires intent to damage property and damages exceeding $1,000.
Morales argued the state had to prove he had at least a criminally negligent mental state as to the amount of damages (i.e., that he was negligent as to whether damages would exceed $1,000).
The state argued no culpable mental state is required with respect to the amount of damages, relying on prior appellate authority.
The court affirmed Morales’s conviction, holding that no culpable mental state is required as to the monetary threshold for first-degree criminal mischief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a culpable mental state is required as to the amount of damages for first-degree criminal mischief	State: no mental state required as to amount; only intent to damage is required	Morales: state must prove at least criminal negligence as to whether damages exceed $1,000	Court affirmed: no culpable mental state required as to amount under ORS 164.365(1)(a)(A)

State v. Jones, 223 Or App 611 (2008) (holding value element of first-degree theft need not be proved with a culpable mental state)
State v. Stowell, 304 Or App 1 (2020) (rejecting a "negligently aware" instruction; value/damage threshold does not require proof of culpable mental state)